Preview
RA-010
ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NUMBER:
Cyrus A. Tabari 133842/Anne Hilleary 136106
NAME:
Sheuerman Martini Tabari Zenere & Garvin
FIRM NAME:
STREET ADDRESS: 1033 Willow Street
CITY: San Jose STATE: CA ZIP CODE: 95125
TELEPHONE NO.: (408) 288-9700 FAX NO.: (408) 295-9900
EMAIL ADDRESS: ctabari@smtlaw.com
ATTORNEY FOR (name): Defendant LOUIS C. LEE, MD
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CRUZ
STREET ADDRESS: 701 Ocean Street
MAILING ADDRESS:
CITY AND ZIP CODE: Santa Cruz CA 95060
BRANCH NAME:
PLAINTIFF/PETITIONER: JAIME VICTORY, ANITA VICTORY
DEFENDANT/RESPONDENT: WATSONVILLE HOSPITAL CORPORATION, ET AL
OTHER CASE NAME: JAIME VICTORY, ET AL. v. WATSONVILLE HOSP
CASE NUMBER:
NOTICE OF REMOTE APPEARANCE
21CV02121
You must use this form to tell the court you intend to appear remotely in a civil case, unless the court's website describes an
online process for giving notice. You may also use it to give the required notice to all other parties in the case. (Do not use
this form in a juvenile dependency proceeding.)
Check the court's website for information about how to appear remotely, including the departments and types of cases or
proceedings that allow remote appearances and ways to appear remotely in their departments for such appearances.
See page 3 of this form for more information, including deadlines for giving notice and for opposing a remote appearance if
this notice is for an evidentiary hearing or trial.
A person appearing remotely should conduct themselves as though appearing in court in person.
1. The person who intends to appear remotely is (check and complete all that apply):
‰ Plaintiff/Petitioner (name):
‰ Attorney for Plaintiff/Petitioner (name):
‰ Defendant/Respondent (name):
‰
X Attorney for Defendant/Respondent (name): Cyrus Tabari/Anne Hilleary
‰ Other (name and role in case):
2. The person or persons in 1 intends to appear remotely (check one):
a. ‰ Throughout the case.
b. ‰X At the proceeding described below, including on any later dates if the proceeding is continued (describe):
Type of proceeding: Case Management Conference
Set on (date): 03/07/2023 at (time): 8:30 a.m. in (department): 5
Before (name of judicial officer, if known): Timothy Volkmann
3. The person intends to appear by (check court's website for method that may be used):
‰X Videoconference ‰ Audio only (including telephone)
4. ‰ For evidentiary hearing or trial only (where testimony may be given): the party requests the following additional aspects of the
proceeding be conducted remotely (describe what the party wants to be done remotely and why; attach form MC-025 if more
space is needed):
Page 1 of 3
Form Adopted for Mandatory Use NOTICE OF REMOTE APPEARANCE Code of Civil Procedure, § 367.75;
Judicial Council of California Cal. Rules of Court, rule 3.672
RA-010 [New January 1, 2022] www.courts.ca.gov
Victory, Jaime-Anita
RA-010
PLAINTIFF: JAIME VICTORY, ANITA VICTORY CASE NUMBER:
DEFENDANT: WATSONVILLE HOSPITAL CORPORATION, ET AL 21CV02121
5. ‰
X I agree to keep the proceeding confidential to the same extent as would be required if I were appearing in person.
Date: March 3, 2023
CYRUS A. TABARI
(TYPE OR PRINT NAME) (SIGNATURE)
Notice to Other Parties
Anyone intending to appear remotely must provide notice to all other parties by the deadlines stated in Cal. Rules of Court,
rule 3.672, and described on the next page. Notice may be provided orally, electronically, or by giving the other parties this
form in a way to ensure it is received by the applicable deadline. The party must tell the court this was done either by filing a
proof of service (this may be done on forms POS-040 or POS-050 for electronic service) or by completing and signing the
declaration below.
SEE ATTACHED PROOF OF SERVICE Declaration of Notice
I gave notice that I intend to appear remotely to the other parties or persons entitled to receive notice in this case as stated below.
Complete one item below for each person notice was given to, and enter one of the following options for "Method of notice" in c.
z Mail: By mailing them a copy of this form (write the mailing address in d.)
z Overnight delivery: By having a copy of this form delivered overnight (write the delivery address in d.)
z Electronic notice: By e-mail or text message (write the e-mail or phone number in d.)
z Phone: By telling them over the telephone or leaving them voice mail (write the phone number in d.), or
z In person: By giving them a copy of this form in person, or by telling them orally in person (write the address in d.)
1. ‰ Plaintiff/Petitioner 2. ‰ Attorney for:
a. Name: a. Name:
b. Date of notice: b. Date of notice:
c. Method of notice: c. Method of notice:
d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) or phone number:
3. ‰ Defendant/Respondent 4. ‰ Attorney for:
a. Name: a. Name:
b. Date of notice: b. Date of notice:
c. Method of notice: c. Method of notice:
d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) or phone number:
5. ‰ Other (specify): 6. ‰ Attorney for:
a. Name: a. Name:
b. Date of notice: b. Date of notice:
c. Method of notice: c. Method of notice:
d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) or phone number:
7. ‰ Other (specify): 8. ‰ Other (specify):
a. Name: a. Name:
b. Date of notice: b. Date of notice:
c. Method of notice: c. Method of notice:
d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) or phone number:
‰ If more people were given notice, check here, attach form MC-025, titled as Attachment Notice, and add the information about
how and when notice was given to each person.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Date: March 3, 2023
Annamarie Obey
(TYPE OR PRINT NAME) (SIGNATURE)
RA-010 [New January 1, 2022] NOTICE OF REMOTE APPEARANCE Page 2 of 3
[page 3 need not be filed]
Victory, Jaime-Anita
1 CASE NAME: Victory v. Watsonville Hospital Corporation, et al. ACTION NO. 21CV02121
2 PROOF OF SERVICE
[CCP §§ 1012.5, 1013a and 2015.5; CRC 2008]
3
I am a citizen of the United States. My business address is 652 North Santa Cruz Ave,
4 Suite A, Los Gatos, CA 95030. I am employed in Santa Clara County where this service
occurred. I am over the age of 18 years and not a party to the within cause. I am readily familiar
5 with my employer's normal business practice for collection and processing of correspondence for
mailing and facsimile. In the case of mailing [other than overnight delivery], the practice is that
6 correspondence is deposited in the U.S. Postal Service the same day as the day of collection in
the ordinary course of business.
7
On March 3, 2023, I served the within Notice of Remote Appearance on the PARTIES
8 in said action as follows:
9 Bruce G. Fagel, Esq. Marc G. Cowden, Esq.
Bronislav M. Draganov, Esq. Adam Stoddard, Esq.
10 Law Offices of Bruce G. Fagel & Associates Zenere Cowden & Stoddard APC
9200 W. Sunset Blvd., Suite 670 2005 De La Cruz Blvd., Suite 240
11 West Hollywood, CA 90069 Santa Clara, CA 95050
Tel: 310-516-9035 mcowden@zcslawfirm.com
12 Fax: 310-928-7763 astoddard@zcslawfirm.com
BruceFagel@fagellaw.com dpoint@zcslawfirm.com
13 BronDraganov@fagellaw.com Attorneys for Defendant
brenda@fagellaw.com Watsonville Hospital Corporation dba
14 pam@fagellaw.com Watsonville Community Hospital
Attorneys for Plaintiffs
15
16 (BY-E-MAIL OR ELECTRONIC TRANSMISSION) Based on a court order or an
agreement of the parties to accept service by e-mail or electronic transmission, I caused the
17 document(s) to be sent to the persons at the e-mail address listed above. I did not receive, within
a reasonable time after the transmission, any electronic message or other indication that the
18 transmission was unsuccessful.
19 X (BY ELECTRONIC SERVICE) I caused each of the above-named documents to be
delivered by email to the parties via One Legal E-Service upload link.
20
X (STATE) I declare under penalty of perjury under the laws of the State of California that
21 the above is true and correct.
22
Dated: March 3, 2023
23
Annamarie Obey
24
25
26
27
28
Preview
RA-010 ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NUMBER: Cyrus A. Tabari 133842/Anne Hilleary 136106 NAME: Sheuerman Martini Tabari Zenere & Garvin FIRM NAME: STREET ADDRESS: 1033 Willow Street CITY: San Jose STATE: CA ZIP CODE: 95125 TELEPHONE NO.: (408) 288-9700 FAX NO.: (408) 295-9900 EMAIL ADDRESS: ctabari@smtlaw.com ATTORNEY FOR (name): Defendant LOUIS C. LEE, MD SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CRUZ STREET ADDRESS: 701 Ocean Street MAILING ADDRESS: CITY AND ZIP CODE: Santa Cruz CA 95060 BRANCH NAME: PLAINTIFF/PETITIONER: JAIME VICTORY, ANITA VICTORY DEFENDANT/RESPONDENT: WATSONVILLE HOSPITAL CORPORATION, ET AL OTHER CASE NAME: JAIME VICTORY, ET AL. v. WATSONVILLE HOSP CASE NUMBER: NOTICE OF REMOTE APPEARANCE 21CV02121 You must use this form to tell the court you intend to appear remotely in a civil case, unless the court's website describes an online process for giving notice. You may also use it to give the required notice to all other parties in the case. (Do not use this form in a juvenile dependency proceeding.) Check the court's website for information about how to appear remotely, including the departments and types of cases or proceedings that allow remote appearances and ways to appear remotely in their departments for such appearances. See page 3 of this form for more information, including deadlines for giving notice and for opposing a remote appearance if this notice is for an evidentiary hearing or trial. A person appearing remotely should conduct themselves as though appearing in court in person. 1. The person who intends to appear remotely is (check and complete all that apply): ‰ Plaintiff/Petitioner (name): ‰ Attorney for Plaintiff/Petitioner (name): ‰ Defendant/Respondent (name): ‰ X Attorney for Defendant/Respondent (name): Cyrus Tabari/Anne Hilleary ‰ Other (name and role in case): 2. The person or persons in 1 intends to appear remotely (check one): a. ‰ Throughout the case. b. ‰X At the proceeding described below, including on any later dates if the proceeding is continued (describe): Type of proceeding: Case Management Conference Set on (date): 03/07/2023 at (time): 8:30 a.m. in (department): 5 Before (name of judicial officer, if known): Timothy Volkmann 3. The person intends to appear by (check court's website for method that may be used): ‰X Videoconference ‰ Audio only (including telephone) 4. ‰ For evidentiary hearing or trial only (where testimony may be given): the party requests the following additional aspects of the proceeding be conducted remotely (describe what the party wants to be done remotely and why; attach form MC-025 if more space is needed): Page 1 of 3 Form Adopted for Mandatory Use NOTICE OF REMOTE APPEARANCE Code of Civil Procedure, § 367.75; Judicial Council of California Cal. Rules of Court, rule 3.672 RA-010 [New January 1, 2022] www.courts.ca.gov Victory, Jaime-Anita RA-010 PLAINTIFF: JAIME VICTORY, ANITA VICTORY CASE NUMBER: DEFENDANT: WATSONVILLE HOSPITAL CORPORATION, ET AL 21CV02121 5. ‰ X I agree to keep the proceeding confidential to the same extent as would be required if I were appearing in person. Date: March 3, 2023 CYRUS A. TABARI (TYPE OR PRINT NAME) (SIGNATURE) Notice to Other Parties Anyone intending to appear remotely must provide notice to all other parties by the deadlines stated in Cal. Rules of Court, rule 3.672, and described on the next page. Notice may be provided orally, electronically, or by giving the other parties this form in a way to ensure it is received by the applicable deadline. The party must tell the court this was done either by filing a proof of service (this may be done on forms POS-040 or POS-050 for electronic service) or by completing and signing the declaration below. SEE ATTACHED PROOF OF SERVICE Declaration of Notice I gave notice that I intend to appear remotely to the other parties or persons entitled to receive notice in this case as stated below. Complete one item below for each person notice was given to, and enter one of the following options for "Method of notice" in c. z Mail: By mailing them a copy of this form (write the mailing address in d.) z Overnight delivery: By having a copy of this form delivered overnight (write the delivery address in d.) z Electronic notice: By e-mail or text message (write the e-mail or phone number in d.) z Phone: By telling them over the telephone or leaving them voice mail (write the phone number in d.), or z In person: By giving them a copy of this form in person, or by telling them orally in person (write the address in d.) 1. ‰ Plaintiff/Petitioner 2. ‰ Attorney for: a. Name: a. Name: b. Date of notice: b. Date of notice: c. Method of notice: c. Method of notice: d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) or phone number: 3. ‰ Defendant/Respondent 4. ‰ Attorney for: a. Name: a. Name: b. Date of notice: b. Date of notice: c. Method of notice: c. Method of notice: d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) or phone number: 5. ‰ Other (specify): 6. ‰ Attorney for: a. Name: a. Name: b. Date of notice: b. Date of notice: c. Method of notice: c. Method of notice: d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) or phone number: 7. ‰ Other (specify): 8. ‰ Other (specify): a. Name: a. Name: b. Date of notice: b. Date of notice: c. Method of notice: c. Method of notice: d. Address (mailing, in-person, or email) or phone number: d. Address (mailing, in-person, or email) or phone number: ‰ If more people were given notice, check here, attach form MC-025, titled as Attachment Notice, and add the information about how and when notice was given to each person. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: March 3, 2023 Annamarie Obey (TYPE OR PRINT NAME) (SIGNATURE) RA-010 [New January 1, 2022] NOTICE OF REMOTE APPEARANCE Page 2 of 3 [page 3 need not be filed] Victory, Jaime-Anita 1 CASE NAME: Victory v. Watsonville Hospital Corporation, et al. ACTION NO. 21CV02121 2 PROOF OF SERVICE [CCP §§ 1012.5, 1013a and 2015.5; CRC 2008] 3 I am a citizen of the United States. My business address is 652 North Santa Cruz Ave, 4 Suite A, Los Gatos, CA 95030. I am employed in Santa Clara County where this service occurred. I am over the age of 18 years and not a party to the within cause. I am readily familiar 5 with my employer's normal business practice for collection and processing of correspondence for mailing and facsimile. In the case of mailing [other than overnight delivery], the practice is that 6 correspondence is deposited in the U.S. Postal Service the same day as the day of collection in the ordinary course of business. 7 On March 3, 2023, I served the within Notice of Remote Appearance on the PARTIES 8 in said action as follows: 9 Bruce G. Fagel, Esq. Marc G. Cowden, Esq. Bronislav M. Draganov, Esq. Adam Stoddard, Esq. 10 Law Offices of Bruce G. Fagel & Associates Zenere Cowden & Stoddard APC 9200 W. Sunset Blvd., Suite 670 2005 De La Cruz Blvd., Suite 240 11 West Hollywood, CA 90069 Santa Clara, CA 95050 Tel: 310-516-9035 mcowden@zcslawfirm.com 12 Fax: 310-928-7763 astoddard@zcslawfirm.com BruceFagel@fagellaw.com dpoint@zcslawfirm.com 13 BronDraganov@fagellaw.com Attorneys for Defendant brenda@fagellaw.com Watsonville Hospital Corporation dba 14 pam@fagellaw.com Watsonville Community Hospital Attorneys for Plaintiffs 15 16 (BY-E-MAIL OR ELECTRONIC TRANSMISSION) Based on a court order or an agreement of the parties to accept service by e-mail or electronic transmission, I caused the 17 document(s) to be sent to the persons at the e-mail address listed above. I did not receive, within a reasonable time after the transmission, any electronic message or other indication that the 18 transmission was unsuccessful. 19 X (BY ELECTRONIC SERVICE) I caused each of the above-named documents to be delivered by email to the parties via One Legal E-Service upload link. 20 X (STATE) I declare under penalty of perjury under the laws of the State of California that 21 the above is true and correct. 22 Dated: March 3, 2023 23 Annamarie Obey 24 25 26 27 28